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FGI response to Ithaka draft values proposition for the FDLP
We've just sent our comments/analysis of the Ithaka S+R "Modeling a Sustainable Future for the Federal Depository Library Program in the 21st Century: Value Proposition" to the project staff and would like to share our comments with the community. Ithaka S+R are still accepting comments so get over to the fdlpmodeling.net site for access to all of their draft documents and leave comments. And by all means, feel free to leave comments, suggestions and ideas for us here as well. We'll share those comments with the Ithaka S+R staff. Ithaka S+R Value proposition: the missing pieces. A Response to the Ithaka S+R "Modeling a Sustainable Future for the Federal Depository Library Program in the 21st Century: Value Proposition"
- Focus on Libraries, not users
- The missing piece: Digital Collections
- A different kind of Value Proposition
[T]his value proposition focuses on considering the costs and benefits of participation in the FDLP from the perspective of a participating (or potentially participating) library under this new Direction and various new Models. While we recognize and celebrate the value that the Program offers to the American public and various specific communities, that value is only discussed here insofar as it contributes to the value proposition of a library. Ultimately, structures that offer positive value propositions encouraging libraries to take on a wide range of roles and responsibilities in support of the overall mission of the Program will directly support the interests of the American public in long-term, no-fee access to government information and support for its effective use. On the other hand, a Program that does not consider the value propositions perceived by the libraries that are expected to serve in critical roles runs the risk of the failure of both the Program and its ability to support the needs of the American public. (p. 3)Thus, rather than building a Program that has value to users, it proposes trying to build a Program that has value to libraries in hopes that they will participate and that their participation will somehow have a trickle down benefit to users. In fact, any value proposition MUST take users into account because library administrators heavily weight gate counts, circulation statistics, and other user measurements as bases for library policies and budgetary decisions. We believe that this logic has three fatal flaws: First, the draft report's focus on the value to libraries results in a skewed and even misleading understanding of the history and future of the FDLP. In the report's description of the value of the FDLP, it repeatedly uses the phrase "many libraries." This phrase implies that there is either a consensus among libraries, or demonstrable trends in one particular direction, or a consistent motivation for changes to the Program. But neither this report nor the earlier FDLP Modeling draft reports document any such consensuses or trends or motivations. If anything, the reports document the diversity of motivations in the FDLP community. In fact, this use of the phrase "many libraries" masks the existence of other views of the value of FDLP. The report tells the story of the historical value of the FDLP from only one perspective -- that of participating libraries and, more specifically, from the perspective of library management (i.e., "What does my library get out of participating in FDLP?"). This narrative of the value of FDLP to libraries is plausible as far as it goes, but it is seriously incomplete. There are other narratives that are as important if not more so. A different narrative, from the point of view of users, for example, would tell a completely different story. It would tell how libraries have helped users find and use government information and have ensured the preservation of that information. It would tell the story of how users are happy today with the access they have to government information on the web directly from agencies. It would also provide a librarian's view of the future of free public access for users and compare the benefits and risks of different models. Such a narrative would illuminate what the different models would actually mean to users, rather than to library managers. Among other things, it would demonstrate the need for building many user-focused services supported by and integrated with specific, user-focused collections. It would result in models that benefit users. Participating libraries would benefit because they would be providing useful services to users. Second, it is not clear that the individual Roles will actually provide any benefit or value to participating libraries. In fact, the report does not even examine the costs and benefits of the Roles, but focuses instead on the Models, which are comprised of Program-oriented broad areas of activity ("Building Blocks") that are implemented through library-oriented Roles. In addition, the descriptions of the Roles in the Models draft report do not adequately define what "participation" in the FDLP Program will mean. It blurs the lines between FDLP libraries and non-FDLP libraries, and between FDLP libraries and libraries that have specialized, non-Title-44 responsibilities. In short, the Values Proposition does not clearly articulate how FDLP participation will provide any benefit over non-participation, or if any of the roles will provide any real value to any libraries. (For more on Building Blocks, Roles and Models, see our previous comments on the draft models report). Third, this approach does not address the biggest issue facing FDLP libraries today: the disintermediation effect of the Web. As documented by the Ithaka S+R Environmental Scan and as repeated in the Values report, users do not see the need for -- and are not using -- libraries as intermediaries to government information. Users are largely happy to search the open Web or go directly to government web sites to get government information. In this context, if participating libraries do not provide demonstrable benefits to their users, no amount of libraries reducing costs and adopting most of the report's Roles (reducing their responsibilities, or drawing down their collections, or unbundling their commitments) will persuade users that libraries are a necessary or useful part of their information seeking and using process. The Models should, indeed, consider the "value propositions perceived by the libraries," but they should do much more. By focusing on the possible value to libraries of ill-defined "participation" in a Program that does not define its value to users, the Value Proposition fails to demonstrate that it will be either sustainable or effective. The missing piece: Digital Collections Although the Ithaka S+R reports go further than any previous analyses of the FDLP in finding value in digital collections and in proposing ways to ensure their long-term preservation, the reports still overlook the value of digital collections to participating libraries, to their users, and to the Program. And, the reports assume -- wrongly in our estimation -- that collections and services can be usefully separated. The Values Proposition report undervalues the importance of digital collections by implicitly adopting several assumptions that GPO promulgated for many years and that most libraries have, until recently, accepted or at least tolerated. These assumptions are: that "tangible" collections are the only collections that provide value to libraries; that digital collections do not provide value to individual libraries; that services and collections can be separated; and that "access" is as good as "ownership." As more and more libraries are building digital collections or contemplating doing so, and, as GPO has recognized that FDLP libraries can be essential partners in digital preservation, these assumptions embedded in the Values Proposition are increasingly anachronistic and simply false. The "unbundling" of collections and services that the draft reports recommend emphasizes the separation of these activities. We believe the final Modeling report would be stronger if it emphasized the need for combining these activities. Such combinations could be done collaboratively by libraries working together or by individual libraries, but they cannot be done successfully if service providers do not have direct control over a collection and how it is built, organized, and presented. The reports do modify these assumptions in one important aspect. They explicitly understand the need for long-term preservation and the importance of (a few) libraries in this role. The draft Values Proposition report does not, however, see any value of smaller libraries (or many libraries) having digital collections and perpetuates the idea of a few libraries handling the bulk of the work. This changes the FDLP from a distributed, participatory system to a centralized, hierarchical system. (For more on this issue, see our comment on the FDLPModeling site) This assumption can be seen most clearly when the report describes the "historical" benefits of participation in the Program:
The declining perceived value realized from tangible government materials combined with the increasing perceived costs of the responsibilities of maintaining these collections poses a complex dilemma for many participating libraries. (p. 5) [I]t is increasingly clear that the exclusivity once enjoyed by depository libraries as the sole venue for accessing government information has largely disappeared. The increasing ability of the average American to access [digital] government information without the intermediary of the depository library has left some depositories questioning the value that they realize by building and maintaining tangible collections of government information. Although the provision of free tangible copies of government information is intended to be one of the core benefits of participation in the Program, many libraries no longer view this as a particularly compelling incentive to participate. (p. 6) [emphasis added]In the above passages, the report blurs the distinctions between digital and "tangible" information and between access and ownership. This results in the implication that, if "tangible" collections are no longer of value to libraries, then digital collections must not be of value either. This is another fatal flaw of the report. We believe that, if digital government information were deposited with FDLP libraries, those libraries would gain from building digital collections many of the same kinds of value that they secured when they built paper collections. And, not only libraries would benefit. There are at least four kinds of value that would result from digital deposit. First, users would gain. Users would benefit if libraries of all sizes addressed the needs of their specific user communities by building digital collections that included authentic, deposited, digital government information along with other digital information. By building such collections, libraries could provide for their user communities (regardless of geographic proximity) rich, unique collections of information from many sources, combined in a common user-interface, augmented by tools for discovery and use, customized for those collections and users. Users would find it easier to locate and use information that best matched their needs, regardless of its original producer or distributor. Rather than having to search for "all" information using generic search engines, or search for information by producer using agency-specific search engines, users could use rich content-specific tools designed and optimized for specific, preselected, quality collections. Additionally, with more libraries building more digital collections, libraries would leverage the inherent nature of the open Web in order to make digital government information more findable. This "seeding the cloud" approach would help users find government information in the same way that links to and from Wikipedia articles and YouTube videos result in higher Google search ranking and thus better findability of information. Second, libraries would benefit. Participating FDLP libraries would have a digital resource that other libraries would not have: authentic, officially-deposited collections that would comprehensively match depositing criteria. By building digital collections of public domain information, the libraries would have a valuable resource for data mining, text indexing, and other computational research. By combining Title-44 materials with non-Title-44 materials, libraries could build unique collections that no other library or agency (including GPO) would have -- collections designed for their relevance to specific user communities. By developing unique tools for discovery, access, and use, FDLP libraries could provide resources and expertise that would contribute to and enrich the digital-library community at-large and gain reputational benefits within that community. Third, the Program would benefit. By encouraging and enabling FDLP libraries to maintain collections of Title-44 digital materials, GPO could more securely guarantee both preservation of and access to those materials. By building online tools that would enable users to easily acquire government information from any of a number of digital libraries seamlessly and transparently, GPO could better ensure long-term, free access even if GPO itself becomes unable to do so. By facilitating the building of a network of digital repositories, GPO could better ensure the long-term preservation of authentic, unaltered copies of Title-44 material. By facilitating the building of collection-specific and user-community-specific tools, GPO could enhance access to Title-44 materials far beyond what it could provide on its own. Fourth, the Library Community would benefit. Every library, not just FDLP libraries, will benefit from having a strong community of digital libraries providing enhanced access and services for government information and rich, unique collections. Government agencies would also fit in this broad category of beneficiaries to the extent that they are like libraries in providing content and services to users. Even though the report articulates the need for some libraries to participate in long-term preservation, by ignoring the value of digital collections to libraries and users, it reduces the opportunities for a more sustainable, effective Program of service and collections. A different kind of Value Proposition We propose instead a different kind of value proposition. We strongly recommend that Ithaka S+R expand its values proposition to examine the benefits to users and the Program, as well as participating libraries. In addition, we suggest that the final report should examine value the way some economists do: by examining the aggregate benefit across all stakeholders. The final report should examine how the Program could maximize this overall social benefit. The final report should ask if changes to the Program increase -- or decrease -- the likelihood that information will be preserved and accessible for the long-term and if changes will increase -- or decrease -- the social benefit that the public gets by actually using, sharing, and reusing government information. Such an approach would change the focus from one side of the equation (library managers, preservationists, GPO, "partners," private sector companies), to both sides of the equation (including users). It should describe policies and Models that would demonstrably maximize benefits to all. The Value Proposition should identify value accrued -- or lost -- to current and future users of government information including citizens in general as well as specific user communities (e.g., economists, historians, journalists, scientists, physicians, geographers, lawyers, students). The Value Proposition should look also at the value to GPO and other government agencies of having a network of many congressionally-mandated (but non-government) libraries participating in the preservation of and providing access to and services for government information. It should consider the value of an FDLP library community to non-FDLP libraries. The existence of such a community would enrich all libraries by providing shared expertise gained through the iterative process of building collections and providing public and technical services for government information. Rather than looking for incentives that might keep libraries nominally in the program while actually drastically reducing their commitment and participation in the Program, the Values Proposition report should describe the benefits of Program changes to users. By providing actual benefits directly to users, libraries will enhance their own relevance and sustainability. By facilitating this, GPO can attract and retain libraries that will gain benefit from sustaining or increasing their commitments rather than from lowering or dropping them. The Blue Ribbon Task Force on Sustainable Digital Preservation and Access (Ithaka S+R's Roger Schonfeld was a contributor to the Task Force) addressed the idea of "Value Propositions" in the digital environment. It said:
"When speaking about value, economists like to ask 'Who benefits?' or 'Who cares?' because well-articulated demand starts with a clear and compelling value proposition about the benefits to be gained by having, in our case, access to information at some point in the future. The value of information is not to be confused with its monetary or financial value per se, although it can often be denominated in currency. The value of digital assets is best understood as what digital materials are good for, and that is usually understood as the ways that the materials are used -- to advance knowledge, entertain or bring pleasure, help solve problems, or inform public policy. "Each user community will identify its own set of values and benefits in the digital materials they demand. For example, in scholarly discourse there is a clear community consensus about the value of e-journals over time." (p. 24)We believe that designing a Values Proposition that directly and explicitly addresses the identifiable needs of and benefits to a wide variety of user communities will be more effective than the current proposition. We believe that such an approach will benefit libraries by benefiting users and will benefit the Program by benefiting libraries. Continue reading
Public comments and response to Ithaka S+R Models draft report
We have sent Ithaka S+R our comments for the draft directions and draft models documents (as well as comments on the other draft documents), but feel that a more in-depth analysis and response is warranted. While there is much to like about this draft -- as other commenters have rightfully pointed out -- it has some serious gaps that could have potentially dire consequences for the future of the FDLP. The main strength of the report is that it explicitly recognizes the need for digital preservation beyond the confines of GPO. The report says:
"Although GPO has taken on an important leadership role in preserving and maintaining the integrity of digital government information, GPO alone cannot effectively accomplish these goals; distributed responsibility for preserving and maintaining the integrity of government information is a long-standing value of the Program that must be maintained in the digital environment to provide users with confidence that the materials they use in digital form will remain available and unchanged over the long term." Continue reading
Public comments on Ithaka S+R draft findings document
Attached for your reading "pleasure" are our collaborative comments on the Ithaka S+R draft findings report released on 1/14/11. Once again, we've done a collective stream of consciousness, inserting comments, suggestions, citations etc within the draft text of the Findings report. Please forward to those individuals, groups and listservs for which the FDLP modeling project has import. And by all means, please contact the Ithaka S+R project team at FDLP-modeling@ithaka.org as soon as possible with your own comments, ideas, suggestions etc. We'd appreciate if any comments sent to Ithaka S+R be posted here in the comments section so that the FDLP community can be informed. Continue reading
Public comments on Ithaka FDLP Modeling Project draft documents (II)
[This is the second of several comments on the Ithaka S+R FDLP Modeling Project. We will tag all our comments so you can find them all here.]
What works and what does not
In this post we'll examine what we can learn from the Ithaka S+R Environmental Scan about existing government information models that are working and those that are not working.
Two developments
The trends that emerge in the report are, for the most part, not surprising to anyone who has been following the trends in information access and libraries over the last two decades. But two developments stand out because of their huge significance to libraries and because they are developments that libraries can control. This is where our choices can make a difference to the future of libraries and the future of free access to government information.
The first development is that of disintermediation. This is the process by which users are increasingly finding that they do not need an intermediary (libraries) to identify, locate, and make use of relevant information. The report describes this development repeatedly in all types of libraries with all types of users.
The second development is the challenge of long term preservation of digital information, which the report describes in some detail in one of its longest sections (p. 24-32).
Which responses to these developments have been effective? Which work and which do not?
Re-intermediation
One of the strategies most often used and advocated by librarians to neutralize the trend in disintermediation is re-intermediation. There are two ways this has been done.
1. Force people to come to you. One way to re-intermediate is to change the environment so that people will once again have to use libraries. Although most librarians do not publicly advocate such an approach, it is the foundation underneath what libraries do when they license access to commercial services (e.g., e-journals, abstracting and indexing services, audiobooks, etc.). In these cases, libraries are benefiting from the restricted access to information imposed by publishers by making libraries a seemingly necessary intermediary. The federal government also uses this model, making some of its information available only for a fee. In some cases FDLP libraries get some sort of free but restricted access to these services, in others libraries have to subscribe to services.
GPO itself has used this model to create a new niche for itself in the digital age. At a time when printing was becoming irrelevant and a government printing office therefore unnecessary, GPO re-intermediated itself into the life cycle of government information by making it virtually impossible for the public to get whole classes of government information without going directly to GPO. It did this partly by refusing to deposit digital government information in FDLP libraries.
Effectiveness. This approach has a short-term, superficial effectiveness since it explicitly re-intermediates the library, but we already know that, in the long-term, it fails. The report describes users who access licensed services remotely but who do not appear to realize that the library is providing an intermediary service; the report implies that these users apparently believe that they no longer need the library. In addition, this strategy of negotiating and enforcing contracts that restrict access to information is not a role that requires librarians or a library. We can conclude that this approach will inevitably lead to these licensing services being provided more efficiently (and less expensively) by a business or legal office of a parent institution. We can also predict that, if we rely on this approach, it will encourage more fee-based government information services (e.g., DARTS, National Climatic Data Center Online Document Library, the Homeland Security Digital Library, Public Health Reports, USA Trade Online, etc.).
In the case of GPO, its success as a sole source of access appears to be hastening, not ending, its own disintermediation. Agencies appear even less likely to use GPO as a "publisher." This results in more information being "fugitive" (outside of GPO and Title 44 control). And, as a sole provider of digital preservation, GPO has no Congressional guarantee of long-term funding to preserve everything forever nor to provide free access forever.
2. Provide New Services. The second way to re-intermediate is more commonly advocated publicly by librarians: It is the idea of creating new services that will attract users. The report mentions many of these "new services": promoting "the library as a place" and as an "information commons," providing internet access and help using the internet, providing computers and software and help using them for specific tasks such as job-hunting, and, in general, offering "higher-value services targeting the particular needs of local constituents." In the area of government information specifically, some librarians strongly advocate libraries promoting themselves as an intermediary between the public and faceless government bureaucracies. Some suggest that government information specialists will do this, others say that all librarians will be trained in government information and there will be no more specialists.
Effectiveness. The report provides little or no evidence that these services are effective in attracting or maintaining users, nor that librarians are uniquely qualified to offer such services. In fact, the evidence in the report's section on "Changing research behaviors and use of libraries" suggests that users are content with the information they can gather without the help of libraries or librarians. Although librarians may wish that users would ask for help and may believe that librarians could help users find better information, there is no reason to believe that users will change their behavior. This approach is little more than an unsubstantiated hope that users will turn to intermediaries at a time when all the evidence demonstrates that users prefer disintermediation.
"Local loading" and building digital collections
The other strategy described by the report is the building of local digital collections, which the report refers to as "local loading." This is a relatively new approach since many libraries have avoided building digital collections or moved slowly to do so. The advantages of doing so are clearly stated in the report as the motivation for choosing this strategy. These include: the need by researchers for dynamic data repositories, the need for curation and digital preservation, the need by users of all kinds to link documents and data, the need of users to have information systems that are enhanced beyond what publishers and producers and distributors provide, the desire by users to have integrated selections of quality resources from different sources, the need by colleges to have enhanced course management applications, the need for better ILL and citation management tools, and the desire of libraries to offer better services and value to a library's users.
Effectiveness. Evidence suggests that organizations that select and acquire digital content and build digital services on top of those collections are successful. Although the report mentions some of these, it neglects to mention some of the key players in this area, giving, perhaps, a diminished impression of their importance. Some of the successful projects include commercial information vendors (e.g, LexisNexis, ProQuest), non-profits (e.g., the Sunlight Foundation, OpenCongress, Govtrack), universities (e.g., the University of Virginia's historical census browser, the Public Papers of the Presidents project at the University of Michigan and University of Wisconsin's "Foreign Relations of the US"), consortia (e.g., CIC, LOCKSS, HathiTrust, OCUL), governments (e.g., data.gov, Thomas, FDsys), special projects (e.g., National Security Archive at George Washington University, collections at the Federation of American Scientists, OpenCRS), as well as projects in the sciences such as arXiv and the collections at the Los Alamos National Laboratory. Perhaps the biggest and most influential in this area are the Google scanning project and the HathiTrust.
All of these share the common strategy of building unique services on top of digital collections that they curate. One of the most important lessons of these projects is that their successes are based on their providing something that no one else does. This is not an artificial "re-intermediation" or a mere hope that users will recognize their need for librarians, but an actual, concrete provision of collections and services that attract users because of their actual value to users.
Benefits to users
It is worth noting that those who oppose building digital library collections often argue that the user does not recognize or care where digital information resides as long as they can access it. This argument misses two essential characteristics of local collections, however.
First, users will see the advantage to using the local digital library collection when the library does something with the content that the remote provider does not (and often cannot) do. Libraries with their own digital collections can provide search and discovery tools that integrate information from many sources; they can provide computational analysis and data mining tools; and they can provide APIs that reflect their users needs for using and repurposing information. Perhaps most importantly, they can combine information from many sources to build unique collections that reflect the interests and needs of their designated user communities. This will make it easier for their users to find what they need without having to sift through irrelevant material on the open web and without having to visit multiple, isolated, proprietary, deep-web/hidden-web sites.
Second, users will derive the benefit of locally maintained collections when libraries keep something online that would have otherwise disappeared. This is where libraries can address the second major trend we identified above: digital preservation. The Ithaka S+R report, unfortunately, confuses this issue by bringing up the old cliche of "access vs. ownership." This hackneyed adage is, today, out of date and misleading. It a false dichotomy because we cannot ensure access unless we have control over the content. Simple "access" to information over which we have no control is at the mercy of those who control the information. In addition, preservation and access are inseparable in the digital world and preservation is inseparable from "ownership," i.e., control. When something is removed from the web (or altered), whether it is accidental or intentional, whether it is done for economic or political reasons, whether it is the "right" decision for one organization or not, the result is the same: the user can no longer access the information he or she needs.
Libraries can prevent information from disappearing and can ensure its long-term preservation. Even smaller libraries that do not see themselves as having long-term preservation as a primary mission will realize that their size often means that their community has information needs that are overlooked by large, monolithic preservation projects. Cooperation and coordination of many small, medium, and large collections will help ensure that information needed by even a small group of information users will not fall through the preservation cracks.
While surveys may not reveal that users understand this as a need today, users will appreciate and understand it in the long run. In the short term, it is librarians who must act now with this long-term vision in mind. Later will be too late. If we fail today, users of tomorrow will recognize our failure and not see a reason to support institutions that did not look after the interests of their communities.
Conclusions
As the Ithaka Findings document notes, "GPO cannot on its own serve as the single trusted party to ensure the preservation and integrity of the digital and digitized FDLP collections." The only question that leaves us with is, Who will work with GPO to preserve and ensure free access for the long-term?
Attempting to make libraries relevant to users in an era of disintermediation by attempting to artificially re-intermediate libraries will fail. Building local digital collections will make libraries relevant to users (in ways that no one else can match) and accomplish digital preservation (which no one else can accomplish alone). Continue reading
FDLP CRS Report: Useful with Reservations #FDLP
April 14, 2012 / Leave a comment
We have had a chance to review the new Congressional Research Service (CRS) Report Federal Depository Library Program: Issues for Congress (Petersen) available at from the Federation of American Scientists, Project On Government Secrecy web site.
While we believe it serves as a useful overview of the Federal Depository Library Program (FDLP), the report has a few significant problems. Members of Congress should consider the following before using this report as a basis for modifying the FDLP:
Report appears to take Ithaka S+R report at face value
Pages 6-11 of the CRS report concern the findings of the Government Printing Office (GPO) commissioned Ithaka S+R FDLP Report (Housewright) and GPO's ultimate rejection of the report. We are concerned that CRS has taken Ithaka's conclusions at face value and have not considered the many criticisms of the Ithaka report. Some of these criticisms included:
We wrote extensively during the Ithaka S+R report period. We were not alone. A complete set of comments that Ithaka S+R received on its project web site is available from GPO. Yet the CRS report authors do not appear to have considered the public comments that questioned a number of Ithaka S+R's findings.
Another curiosity is CRS's omission of GPO's reasoning for rejecting the Ithaka S+R report. The authors simply note that "GPO did not provide a detailed, publicly available explication of its decision." It seems to us that it would have been appropriate and useful for CRS to have contacted Superintendent of Documents (SuDoc) Mary Alice Baish and interviewed her about GPO's rejection of the Ithaka S+R report. In doing so, CRS could have expanded the existing public record with more details from GPO as to why the report was unacceptable and given the report an additional depth of understanding. Given the GPO rejection of the Ithaka S+R report and the amount of criticism of the report from the library community, CRS's reliance on the report results in a description of the FDLP that is both limited and slanted.
Threats to access to digital government information
Pages 13-14 of the CRS report address "Access to Digital Government Information." The section concludes with the following:
Although these are legitimate questions, CRS left out bigger problems within which these questions are merely details of implementation. These bigger problems stem from the GPO-centric model of the FDLP in which GPO has usurped from libraries the roles of both preservation and access. By replacing libraries, GPO has endangered the long-term future of information preservation and free-public access to that information in many ways. Three of the most important of those are, uncurated access, the term we call "silent withdrawals," and the very real potential of inadequate funding of GPO along with the complementary danger of replacing of free access with fee-based access.
Uncurated access
Access to government information has been a key tenet of the FDLP for 200 years. CRS averred that fact when they stated, "emergence of digital delivery of government information outside the FDLP program may offer increased access to government information to those who might not be able to visit depository libraries." But the key point missed by CRS is the idea of uncurated access. By only discussing access, but not preservation, CRS ignores the processes carried out by depository institutions to *preserve* govt information. We have said many times on FGI that access today does not equal access in the long-term. Libraries have begun to put processes in place to assure long-term digital access (University of North Texas Digital Library, LOCKSS-USDOCS, Archive-it collections, End-of-term crawls etc). Librarians can and should continue their curatorial responsibilities in the digital realm. We can't expect GPO and other government agencies -- especially in this budget crisis climate -- to have the long-term vision necessary to assure long-term preservation. Curation and content control will be key issues going forward. These issues were merely glossed over by the report.Silent Withdrawals
One of the many strengths of a distributed depository system is the way its very structure protects information from intentional or unintentional loss, censorship, or erasure. Without this protection, information can too easily be withdrawn "silently" -- that is, without public announcement or review. That FDLP works is evident when one compares information in the depository system to information not in the depository system. The number of documents that have been sent to depository libraries and later withdrawn is relatively small and the reasons for the recalls are usually not controversial.
- Federal publications recalled from libraries. (1981-2010). Stanford University Library.
Contrast this to information that has been withdrawn from the web, reclassified by agencies, and documents that have had open access restricted by agencies after their release:The reason for the success of the depository system is that it has checks and balances and procedures that must be followed when an agency wishes to withdraw a publication ("ID 72" GPO 2005). In the world of physical deposit of print documents, withdrawal of a previously deposited document requires the compliance of tens or even hundres of libraries that actually have physical possession and control of copies. While depository librarians have a legal obligation to comply with withdrawal and destroy orders, there have been cases where this step triggered complaints about unreasonable withdrawal requests. Such questioning has led agencies to withdraw requests that seemed based on embarrassment or paranoia rather than error or true security needs.
One noteworthy example of this comes from 2001 when the CIA put pressure on the Department of State to destroy already-printed volumes of the Foreign Relations of the United States, 1964-1968, V. 16, Cyprus, Greece, and Turkey. But those volumes were in the possession of GPO and slated for deposit with FDLP libraries (Aftergood). The volumes were not destroyed and were distributed (S 1.1:964-68/v.16).
Another example comes from 2004 when the Justice Department demanded that depositories destroy copies of five publications that dealt with, among other things, how citizens can retrieve items confiscated by the government. The American Library Association objected, the Justice department rescinded its order, and GPO allowed libraries to keep copies and also replaced copies already destroyed. (Lee)
GPO's policy does have good procedures to prevent "silent withdrawals" even of information that is not physically deposited with libraries. But when GPO does not deposit digital copies with libraries, depositories are cut out of the procedures and an important safeguard is missing. Withdrawal decisions and their execution stay wholly within the federal government -- making it easier for the government to remove items from public access. The "LOCKSS-USDocs" private LOCKSS network project is beginning to replace this safeguard, but more work is needed to ensure digital deposit with more libraries in order to guard against silent withdrawals.
Budget Problems
The current GPO-centric model of digital access described, and apparently unquestioned, by CRS has a single point of failure. If Congress decides it is no longer worthwhile to adequately fund information dissemination in general or GPO in particular, users and libraries will lose access to material unique to GPO's servers. Even the maintenance of so-called "persistent" URLs (PURLs) could be endangered by something as simple as inadequate funding.
Digital information requires long-term, consistent funding. Neither digital information preservation nor access can be accomplished passively: both require constant attention and renewal and resources. Even budget cutbacks can cause loss of information or loss of access to information. The single-point-of-failure GPO-centric model of preservation and access is a system in which even inadequate funding means loss of information.
Reduced funding can also lead to privatization of government information access. This can occur if the fee-based private-sector takes over the delivery of services that GPO drops because of inadequate funding. It can also occur if Congress mandates that GPO use a fee-for-service model. In both cases, free access will be lost and people and libraries may be unable to afford adequate access. (Jacobs)
An April 10, 2012 Federal Times demonstrates that GPO is already feeling a lot of pain:
To make ends meet, GPO is also focusing on money-making activities like making secure credentials for the FBI. At its heart, the FDLP is a cost center. It has no opportunity to make GPO profit. This is right and proper, but will continue to make the FDLP a tempting target in future budget reductions. (Jacobs)
SummaryAny discussion of disruptions in user access needs to acknowledge the above facts. As long as digital storage is centralized in GPO, free and permanent access is only a Congressional Act away from being disable or terminated. The report does ask a key question: what solutions might create a more robust FDLP that is better equipped to meet the demands of providing government information to American citizens." We at FGI and many allies in the FDLP community have been working on that question (see Letter to Deputy CTO Noveck: "Open Government Publications," Rethinking the Cloud, and Achieving a collaborative FDLP future to contextualize the issues involved).
The report written by Petersen, Manning and Bailey provides a useful historic overview of the FDLP. We feel that it somewhat mischaracterizes recent efforts at building consensus. Most seriously, the report leaves out major barriers to free, permanant public access to government information that MUST be addressed in any meaningful reform effort.
References:
- Aftergood, Steven. State Dept Mulls "Book Burning." Secrecy News (September 21, 2001)
- Housewright, Ross, and Roger C. Schonfeld. Modeling a Sustainable Future for the United States Federal Depository Library Program’s Network of Libraries in the 21st Century, Final Report of Ithaka S+R to the Government Printing Office, Ithaka S+R, May 16, 2011, Including "Statement from the U.S. Government Printing Office" by Mary Alice Baish (August 5, 2011)
- Jacobs, James A. Privatization of GPO, Defunding of FDsys, and the Future of the FDLP, FreeGovInfo (2011-08-11).
- Lee, Christopher. Justice Dept. Rescinds Order to Pull Publications.
Washington Post (August 5, 2004) page A17.
- Lipowicz, Alice. Digital information may strain GPO and library system, CRS says, Federal Computer Week(Apr 11, 2012)
- Petersen, R. Eric, Jennifer E. Manning, and Christina M. Bailey. Federal Depository Library Program: Issues for Congress by Petersen, Congressional Research Service CRS Report R42457 (March 29, 2012)
- Reilly, Sean. Cost-cutting saves GPO from financial crisis, chief says. Federal Times, (4/10/2012).
- Replacement copies of five DOJ documents for depositories that had removed them. Judith C. Russell, Superintendent of Documents (August 5, 2004)
- U.S. Government Printing Office. Managing Director, Information Dissemination, Superintendent of Documents. Information Dissemination Policy Statement 72 (ID 72). "Withdrawal of Federal Information Products from GPO’s Information Dissemination (ID) Programs." Effective Date: June 21, 2005, Supersedes No.: SOD 72 Dated: 07/22/02.
- LOCKSS-USDOCS private LOCKSS network: The Digital Federal Depository Library Program.
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